G.R. No. L-6054
THE INSULAR GOVERNMENT, plaintiff-appellant, vs. THE ROMAN CATHOLIC BISHOP OF NUEVA SEGOVIA, defendant-appellee.
December 10, 1910

FACTS:
In original proceedings under Act No. 627 , the Court of Land Registration issued an order declaring certain lands to be public lands. Subsequently, a motion to vacate a part of this prior order was filed within the same original proceedings. The Court of Land Registration granted the motion, issuing an order that vacated a part of its earlier declaration without making any further disposition of the case. The Insular Government (appellant) appealed this vacating order. The Roman Catholic Bishop of Nueva Segovia (appellee) filed a motion to dismiss the appeal.

ISSUE:
Was the order vacating a part of a prior order, issued in the same proceedings, a final order subject to appeal, or a mere interlocutory order not subject to appeal?

RULING:
The Supreme Court reiterated its long-standing doctrine that appeals are allowed only from final judgments that completely dispose of and finally determine the action or proceeding. An order is considered final if it terminates the litigation between the parties, leaving nothing to be done but to enforce what has been determined. Conversely, an interlocutory order does not end the suit but leaves something to be done by the court.

The Court held that the vacating order in this case was issued in the same original proceedings and merely set aside a part of a previous order. It did not make a final disposition of the proceedings; instead, it left the matters affected by the vacated part open for further action by the lower court. Therefore, the order was interlocutory and not appealable. The Court distinguished this from a judgment rendered in an independent action brought to vacate a prior judgment, which would be appealable because the independent suit itself would be concluded.

Accordingly, the appeal was dismissed.